Subject: Re: The Truth about APT's Section 706 Petition
John Schwartz (schwartz@usa.net)
Date: Fri, 05 Jun 1998 15:55:26 -0600
Message-Id: <3.0.3.32.19980605155526.0073546c@postoffice.att.net> Date: Fri, 05 Jun 1998 15:55:26 -0600 To: roundtable@cni.org From: John Schwartz <schwartz@usa.net> Subject: Re: The Truth about APT's Section 706 Petition In-Reply-To: <3578231A.52B2@apt.org>
Thanks for taking the time to write such a detailed account of the APT
position. I have some follow-up questions.
Maureen Lewis <mlewis@apt.org> wrote:
>
> As for the substance, APT is seeking modification of existing FCC rules
> that it believes are disincentives to investment in advanced networks.
[snip]
> --APT has never endorsed monopolistic provisioning of advanced data
> services. On the contrary, it has urged availability of "dry copper"
> loops to CLECs so they can provide their own advanced services.
If competitors cannot lease access to ILEC switching and---even more
significant--- cannot colocate facilities at ILEC wire centers, of what
avail are dry loops? Further, recent experience here in Colorado with
U S West's xDSL deployments indicates that dry copper loops are often
unavailable.
> Suggestions about limiting Sec. 251 unbundling requirements relate
> solely to widely available elements like switches and transport and
> exclude the loop. APT Pet. at 20.
Is it APT's view that such unbundling inhibits investment? If so, the
logic is not immediately obvious to me. If not, what is the rationale for
imposing such limits?
> --RBOC entry into long distance is not raised in these filings. The
> petition does, however, recognize that Sec. 10 of Telecom Act requires
> full implementation of Secs. 271 and 251 before FCC can forbear
> enforcement of 251(c).
This appears circular to me. If Section 251 is implemented initially, and
then the FCC forbears from enforcing 251(c), and then ILECs cease to comply
with 251(c), the process of opening ILEC networks will be frustrated.
J.
_____________________________________________________________________________
John B. Schwartz
P.O. Box 6060 Telephone 303-442-2707
Boulder, CO 80306 FAX 303-442-6472
schwartz@usa.net
_____________________________________________________________________________
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